Luxottica Group, S.p.A. (LUX)

CODE OF CONDUCT CONCERNING INTERNAL DEALING

        The Code on Internal Dealing approved by the Board of Directors provides detailed rules applicable to the trading in financial securities by persons who have access to relevant confidential information. The rules relate not only to behavior but also to the protection and control of confidential information.

        The following are considered to be "relevant persons":

•

Luxottica's Directors and Statutory Auditors;



•

the division/department heads reporting directly to the Chairman, the Deputy Chairman and the Chief Executive Officer; and



•

the Chief Financial Officer, the Chief Accounting Officer and the Chief Operating Officer of the retailing division of North America and the Exec. Vice President of North America.

8

        Any "relevant person" trading in financial securities issued by Luxottica must give the market written notification of having done so.

        In the case of the trade having a counter-value in excess of euro 50,000 but less than or equal to euro 250,000, notification must be made by the relevant persons within five working days following the end of the quarter in which the trade was made.

        In the case of a trade having a counter-value in excess of euro 250,000, notification must be made with no delay and in any case by the second open market day following the trade.

        The Code on Internal Dealing includes certain black-out periods in which trading is not permitted as well as a system punishing any breaches of the Code.

CODE OF CONDUCT CONCERNING INTERNAL DEALING

        The Code on Internal Dealing approved by the Board of Directors provides detailed rules applicable to the trading in financial securities by persons who have access to relevant confidential information. The rules relate not only to behavior but also to the protection and control of confidential information.

        The following are considered to be "relevant persons":

•

Luxottica's Directors and Statutory Auditors;



•

the division/department heads reporting directly to the Chairman, the Deputy Chairman and the Chief Executive Officer; and



•

the Chief Financial Officer, the Chief Accounting Officer and the Chief Operating Officer of the retailing division of North America and the Exec. Vice President of North America.

8

        Any "relevant person" trading in financial securities issued by Luxottica must give the market written notification of having done so.

        In the case of the trade having a counter-value in excess of euro 50,000 but less than or equal to euro 250,000, notification must be made by the relevant persons within five working days following the end of the quarter in which the trade was made.

        In the case of a trade having a counter-value in excess of euro 250,000, notification must be made with no delay and in any case by the second open market day following the trade.

        The Code on Internal Dealing includes certain black-out periods in which trading is not permitted as well as a system punishing any breaches of the Code.